When should time be used instead of MDM to select an E/M code?

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Time should be used instead of the Medical Decision Making (MDM) criteria to select an Evaluation and Management (E/M) code when more than 50% of the total face-to-face encounter is devoted to counseling and/or coordination of care. This guideline applies primarily to outpatient E/M services.

Here’s why and when time-based coding is appropriate:

1. Counseling/Coordination Dominates Visit: If the provider spends the majority of the visit explaining diagnoses, discussing treatment options, obtaining informed consent, or coordinating care with other providers or family, time better reflects the complexity of the visit than MDM.

2. Documentation of Time: The total time spent on the date of the encounter—including face-to-face and related activities like reviewing records, communicating with other providers, or documenting—must be clearly documented.

3. Applicable Services: Time-based coding is commonly used for outpatient office visits, hospital visits, and some other E/M services where counseling or coordination is significant.

4. Use of Time Tables: The current CMS and AMA guidelines specify time ranges for each E/M level (e.g., 99214 typically requires 30–39 minutes).

5. No MDM Requirement: When using time, MDM complexity is not factored into code selection.

In summary, time is used instead of MDM to select an E/M code when counseling/coordination dominates the visit (>50% of time), and the total time spent on the encounter is thoroughly documented to justify the code level.

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